The
inclusion of a statutory levy within the Gambling White Paper is a commitment
that is very precious and comes with great responsibility, both
for the commissioner/s who will distribute the funds and for the organisations
who access the funds to provide their services. The United Kingdom’s eco-system
to reduce gambling harms is, in the main, world-class. I hope the significant
uplift in funding arising from the statutory levy is a fundamental catalyst for
innovation as to how funds are distributed by the commissioner/s with the approach
of supporting organisations with core sustainable funding first, then
innovation funding second.
This paper
shares some of my own learning and observations on funding for services and
research, having worked predominantly in the third sector for over thirty
years, of which ten years have been spent in the gaming space. The third sector
is incredibly special, bursting with talent, entrepreneurship and a real sense
of purpose. It is also a sector which has to demonstrate the Public Benefit
test at the point an organisation is incorporated and has to also evidence
value for money and social impact. These qualities alone I would hope mean the
third sector will continue to play its part in reducing gambling harms in the
United Kingdom, alongside the NHS and other agencies in a coordinated, positive
and solutions focus manner; free of any vested interests or showboating.
I have no
doubt that all the organisations on the current Gambling Commission RET list
will be able to find commonality, understanding, and unity and contribute
purposeful insight to the upcoming consultations. Building upon the experience
of these organisations of what works will no doubt accelerate a new collectively
owned national strategy to reduce gambling harms and that is why we should
recognise, support and celebrate our world-class eco-system. The current
Gambling Commission RET list already draws on sharing global expertise, insight
and services and is a real asset from the previous national strategy.
Looking at
the current transition period that we are now in, organisations that are part
of the National Gambling Support Network (NGSN) and therefore funded by
GambleAware, principally for treatment have a structure to contribute as a
collective voice to the various consultations and stakeholders. Those organisations
who are not part of the NGSN, I sense do need a collective voice and strong leadership
to define and establish the areas of commonality to also present to various
consultations and stakeholders. I am particularly thinking of research, prevention
and start-up organisations here. Having a broad church of collective voices is
more important now than ever.
This paper aims
to share two specific foundations on which a statutory levy may be initially organised
and funding distributed. It has been written through the lens of (i) delivering
social impact in a timely manner, ensuring value for money and transparency with
a two-step approach to the production of any new strategy and (ii) what organisations
might need who are currently in this space (i.e. those on the Gambling
Commissions RET List) to contribute to the development of this strategy during
the first year.
Strategy
Outcome one: An initial one-year enabling plan by bringing the support ecosystem
together.
Outcome two:A comprehensive three-year strategy to
reduce gambling harms in the United Kingdom
It takes time to develop a good, insightful strategy but equally, the
task also creates a wonderful opportunity to bring the sector together. To my
knowledge, the rich and diverse range of organisations which are currently on
the Gambling Commissions RET list haven’t come together as a whole to look at
strategy and coordination, might this be a useful starting point.
I suspect any strategy would take approximately twelve months to create
and so might an initial one-year enabling plan provide a useful framework to build
a level of consensus among everybody in the current support eco-system (i.e. particularly
bringing together the NGSN and non-NGSN organisations), develop shared
understanding and trust among organisations and finally share insight into what
will be a full collectively owned national strategy to reduce gambling harms in
the United Kingdom.
In addition to the above particularly non-NGSN organisations might
benefit from a transition plan and the leadership to establish themselves as a
collective and credible voice. Funding for these organisations remains a
challenge and expecting operators to step in with funding solves an immediate funding
challenge, but some non-NGSN organisations need more than an immediate sticking
plaster which funding provides.
Developing a collectively own, fully costed national strategy to reduce
gambling harms and one where progress can be measured in a straightforward
manner will require some intensive work to be undertaken if it is to be
delivered in a timely manner. Writing the actual strategy is in many ways the
easy part; putting a budget to it, making it easily measurable and collating
the evidence will be the trickier challenge. Organisations contributing need to be
compensated for their time and if we are to develop this as an inclusive process,
there should be a level of parity among all organisations on the Gambling
Commission RET list to enable this to happen.
Therefore a
programme of quarterly in-person consultations and strategy days might be
developed to enable organisations to come together for all the advantages above.
There are currently thirty organisations only on the Gambling Commission RET
list and so this will be an ideal size for such work to be completed. There are
some noticeable organisations in our sector that are not on the Gambling
Commission RET list and they should also be invited to ensure an inclusive
process and as a way to build trust.
To ensure
these meetings have structure and purpose, a one-year enabling or transition plan
should be created. This should set out the process and deliverables to create a
new national strategy within a twelve-month period. A new strategy is
fundamental, otherwise, we risk not grasping the opportunities afforded by the precious statutory levy for absolute coordination, reporting progress, value for
money and evaluation.
Initial funding distribution and training
Outcome one: Initial
core funding to be granted to organisations on the Gambling Commission RET list
Outcome two: Leaders with Lived-Experience to be offered training
to degree or masters level.
There are to
my mind two challenges with the current funding arrangements for those on the
Gambling Commissions RET list; one is how funding is currently collected and distributed
to organisations in the support sector; the second is around core funding more
generally for the wider third sector. It should be noted that being on the
Gambling Commission RET list doesn’t explicitly guarantee funding, however, it
is a RET list of two halves and does the statutory levy again present an
opportunity to innovate and in many ways recognise the contribution made by all
organisations on the Gambling Commissions RET list and their contribution to our
sector.
With the
period of upcoming remote consultations (and potential in person
consultations), we do have the means to compensate organisations for
contributing by funding a percentage of their core costs as a one-off in this
period of transition. This would be a huge enabler, particularly for smaller and
non-HGSN funded organisations to give their insight and expertise (as appose to
these organisations consistently living month-by-month where income may be the
number one priority). There is plenty of
funding in the eco-system to support such an approach. There would be many ways
to consider this distribution of this one-off funding, one way might be:
Organisations
with a turnover under £500k in 2021/2022: Review the last set of filed accounts with
Companies House or the Charity Commission and make a core funding allocation
equivalent 50% of their most recent turnover filing. For example,
Organisation A turned over £185,000 in their latest accounts. Make a core contribution
of £92,500
Organisations
with a turnover greater than £501K 2021/2022: Review the last set of filed accounts with
Companies House or the Charity Commission and make a core funding allocation
equivalent to 25% of their most recent turnover filing. Only work which
contributes to the UK’s national strategy to reduce gambling harms would be
included. For example, Organisation B turned over £2,300,000 in their latest
accounts. Make a core contribution of £575,000.
Start-up
organisations: A
couple of organisations on the Gambling Commission RET list would not have
filed their first-year accounts. These would be looked at on a case-by-case
basics with a view to offering a contribution, of no greater than 50% of income
as per their latest bank statements or similar.
Again to
ensure inclusivity, this core funding would apply to all organisations on the
Gambling Commissions RET list.
In addition
to this core funding, as a sector, we have encouraged people with the
lived-experience of gambling harms to step forward and contribute. Some have
chosen to contribute by establishing organisations, which have since been added
to the Gambling Commissions RET List. For many of these organisations accessing
funding is incredibly difficult due to a range of factors. I also sense that
many of these people are first-time Chief Executives, so while they may have
passion and energy in abundance, that unfortunately isn’t enough to develop and
lead a successful organisation in most cases. Therefore distributing an element
of core funding as shown above, with the expectation of external training,
might enable organisations, particularly those led by leaders with
lived-experience to (i) contribute to all consultations, while their service
delivery continues via a core funding contribution (ii) offer all leaders with
lived experience who lead organisations the opportunity to study for a Level 6
(degree) or Level 7 (Masters) Apprenticeship in Senior Leadership. This
training could be fully funded via an apprenticeship levy transfer.
There is no
doubt the statutory levy will bring a host of new organisations into this space
and the procurement and tendering for services in the future will be incredibly
competitive. Both of these are strong positives for a new national strategy to
reduce gambling harms and absolutely should be encouraged. However in this
transition period finding a way to recognise, celebrate and support the current
eco-system and train the lived-experience leaders of the future would be
another welcome gesture and a positive bringing to the end the current
arrangements. It also gives leaders with lived experience the best chance to
succeed in a new and highly competitive statutory funding environment. I am
grateful to Mark Conway and others who have contributed their insight to this
paper and we hope this provides a starting point for a conversation.
Lee WillowsMay 2023
About
the author:Lee
Willows is a social entrepreneur having spent thirty-two years in the Third Sector
leading the work of national charities. He is the founder of Young Gamers &
Gambling Education Trust and ESG Gaming where he is using his lived experience
of gambling harms to deliver social impact. Lee also works for Virgin StartUp,
where he coaches and mentors entrepreneurs supported by Virgin and is currently
undertaking an MBA, reading Senior Leadership in safer gaming and web3.